Electronic Funds Transfer (EFT) Payments and CHOWs
If – pursuant to the CHOW – the seller submits a Form CMS-855B voluntary termination application, the contractor shall contact and explain to the seller that the ambulatory surgical center/portable x-ray supplier will not receive any payments until the RO approves the CHOW. (This is because payments must be sent to the seller until the tie-in/approval letter is sent). If the seller insists that its application be processed, the contractor shall process it; however, it shall first notify the facility/new owner and explain that payments will cease once the seller’s termination is effective.
Ambulatory Surgical Centers (ASCs)/Portable X-ray Suppliers (PXRS) Tie-In/Tie-Out Notices and Referrals to the State/RO
(For purposes of this section 15.7.8.4, the terms “tie-in notices” and approval letters will be collectively referred to as tie-in notices. “Tie-out notices” are notices from the RO to the contractor that, in effect, state that the ASC’s/PXRS’s participation in Medicare should be terminated.)
A. Issuance of Tie-In/Tie-Out Notices
A tie-in or tie-out notice is generally issued in the following circumstances:
1. Initial enrollments
2. CHOWs
3. Voluntary terminations
4. Involuntary terminations (e.g., supplier no longer meets conditions of coverage) prompted by the state/RO.
With the exception of voluntary and involuntary terminations, each of the transactions described above requires a referral and recommendation to the state/RO.
(Depending on the specific RO, certain changes of information may also result in the issuance of a CMS-2007.)
B. Form CMS-855B Changes of Information, Stock Transfers, and Other Transactions
1. Referrals to State/RO
The following is a list of transactions that require a recommendation and referral to the state/RO:
• Addition of practice location
• Stock transfer
• Change in practice location or address in cases where a survey of the new site is required
In these situations, the Provider Enrollment, Chain and Ownership System (PECOS) record should not be switched to “approved” until the contractor receives notice from the RO that the latter has authorized the transaction. However, if the contractor knows that the particular state/RO in question typically does not review, approve, or deny this type of transaction, the contractor need not send the transaction to the state/RO for approval and shall instead follow the instructions in (B)(2) below.
(If the transaction is a stock transfer, the contractor need not send the transaction to the state/RO for approval (and shall instead follow the instructions in (B)(2) below) if the following three conditions are met:
(1) The contractor is confident that the transaction is merely a transfer of stock and not a CHOW,
(2) The RO in question (based on the contractor’s past experience with this RO) does not treat stock transfers as potential CHOWs, and
(3) The contractor knows that the particular state/RO in question does not review, approve, or deny this type of transaction.
If any of these 3 conditions are not met, the contractor shall send the transaction to the state/RO for approval.)
RO approval for the transactions listed in (B)(1) may be furnished to the contractor via tie-in notice, letter, e-mail, fax, or even telephone; the contractor may accept any of these formats.
If the RO (after receiving the transaction from the contractor for review) notifies the contractor that it does not normally review/approve/deny such transactions, the contractor may finalize the transaction (e.g., switch the PECOS record to “approved).
2. Post-Approval RO Contact Required
Changes that do not mandate a recommendation to the state/RO but do require postapproval correspondence with the RO include: • Deletions/voluntary terminations of practice locations or subunits
• Legal business name, tax identification number or “doing business as” name changes that do not involve a CHOW
• Address changes that do not require a survey of the new location
• The transactions (excluding stock transfers) described in (B)(1) for which the contractor knows that the state/RO does not issue approvals/denials
• Stock transfers for which the 3 conditions mentioned in (B)(1) are met.
For these transactions, the contractor shall: (1) notify the supplier via letter, fax, e-mail, or telephone that the change has been made, and (2) switch the PECOS record to “approved.” The contractor shall also notify the state and RO of the changed information (via any mechanism it chooses, including copying the state/RO on the notification letter or e-mail) no later than 10 calendar days after it has completed processing the transaction. The notice to the state/RO shall specify the type of information that is changing.
3. All Other Changes of Information
For all Form CMS-855B change requests not identified in (B)(1) or (B)(2) above, the contractor shall notify the supplier via letter, fax, e-mail, or telephone that the change has been made and shall switch the PECOS record to “approved.” The state and RO need not be notified of the change.
4. Revalidations, Reactivations and Complete CMS-855 Applications
In situations where the provider submits a: (1) Form CMS-855B reactivation, (2) Form CMS-855B revalidation, or (3) full Form CMS-855B as part of a change of information (i.e., the supplier has no enrollment record in PECOS), the contractor shall make a recommendation to the state/RO and switch the record to “approval recommended” only if the application contains new/changed data falling within one of the categories in (B)(1) above. For instance, if a revalidation application reveals a new practice location that was never reported to CMS via the Form CMS-855B, the contractor shall make a recommendation to the state/RO and await the RO’s approval before switching the record to “approved.” In this situation, the contractor should forward the application to the state with a note explaining that the only matter the state/RO needs to consider is the new location.
If the application contains changed data falling within one of the categories in (B)(2) above, the contractor can switch the PECOS record to “approved.” The contractor shall also notify the state and RO of the changed information (via any mechanism it chooses, including copying the state/RO on the notification letter or e-mail) no later than 10 days after it has completed processing the transaction.
C. Supplier-Specific, Non-CMS-855 Changes
If the contractor receives a tie-in notice or approval letter for a transaction that concerns information not collected on the Form CMS-855B application, the contractor need not ask the supplier to submit a Form CMS-855B change of information.
D. Involuntary Termination Prompted by State/RO
If the contractor receives a tie-out notice from the RO that involuntarily terminates the supplier’s Medicare participation because the supplier no longer meets the conditions of coverage, the contractor need not send a letter to the supplier notifying it that its Medicare participation/enrollment has been terminated. The RO will issue such a letter and afford appeal rights.
The contractor shall adhere to the instructions in section 15.27.2 of this chapter with respect to revoking the supplier’s enrollment.
E. Other Procedures Related to Tie-In/Tie-Out Notices and Approval Letters
1. Receipt of Tie-In When Form CMS-855B Not Completed
If the contractor receives a tie-in notice or approval letter from the RO but the supplier never completed the necessary Form CMS-855B, the contractor shall have the supplier complete and submit said form. This applies to initial applications, CHOWs, practice location additions, etc., but does not apply to the cases described in subsection C above.
2. Delegation to State Agency
There may be instances when the RO delegates the task of issuing tie-in/tie-out notices or approval letters to the state agency. The contractor may accept such notices from the state in lieu of those from the RO. However, the contractor should first contact the applicable RO to confirm: (1) that the RO has delegated this function to the state, and (2) the specific transactions (e.g., CHOWs, site additions) for which this function has been delegated.
3. Review for Consistency
When the contractor receives a tie-in notice or approval letter from the RO, it shall review its contents to ensure that the data on the notice/letter matches that on the Form CMS-855B. If there are discrepancies (e.g., different legal business name, address), the contractor shall contact the applicable RO to determine why the data is different.
4. Creation of New Logging and Tracking (L & T) Record Unnecessary
The contractor is not required to create a new L & T record in PECOS when the tie-in notice or approval letter arrives, as the existing record should not be in a final status and can therefore be modified. Simply changing the L & T status is sufficient.
5. Supplier Inquiries
Once the contractor makes its recommendation for approval to the state/RO, any inquiry the contractor receives from the supplier regarding the status of its request for Medicare participation shall be referred to the state or RO.
6. Timeframes
So as not to keep the PECOS record in “approval recommended” status interminably, if the contractor does not receive notification of approval from the RO after what it deems to be an excessive amount of time, it may contact the RO to see if such approval is forthcoming.
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